Allen_AmendedClosurePlan_Rev1_CoverLetter_20200805

f� DUKE
ENERGY
August 05, 2020
ELECTRONIC MAIL AND UPS
Ms. Shelia Holman
Assistant Secretary
North Carolina Department of Environmental Quality
1611 Mail Service Center
Raleigh, NC 27699-1611
RE: Allen Steam Station Ash Basin Closure Plan (Amended, Revision 11
Paul Draovitch
Sersor Vice President
EHS and Ops Support
526 South Church Street, Mail Code: EC3XP
Charlotte. MC M902
Phone: [phone]
Email:#� L�"ea �y C"
On January 30, 2020, Duke Energy submitted an amended (Revision 0) Ash Basin Closure Plan detailing the full
excavation of the Active Ash Basin (AAB) and Retired Ash Basin (RAB), including the excavation of the landfill within the
RAB In accordance with the requirements of North Carolina General Statutes § 130A-309.214(a)(4) and Paragraph 12 of
the Settlement Agreement entered into by and between Duke Energy, the North Carolina Department of Environmental
Quality (NCDEQ), and certain community groups.
After further discussions and review, Duke Energy has revised the Ash Basin Closure Plan (Amended, Revision 1) to allow
placement of all CCR, except for a small amount of coal ash that is necessary for transmission tower stability, to (3) three
new lined landfills, rather than (2) two landfills which was submitted on January 30, 2020 as the Amended Closure Plan,
Revision 0. Excavation and placement of the ash in the originally proposed two landfills was found to be difficult to
sequence and operate. By evaluating likely excavation sequencing, we found that constructing two starter landfills and
one primary landfill would facilitate ash excavation, ease staging landfill cell construction, and would reduce the overall
cost of closure. The landfills are within plant property and are located partially within the prior footprint of the AAB and
RAB ash basins (Basins).
Closure activities for the Basins have already begun with the completion of decanting under the Special Order by
Consent (SOC No. S17-009). While waiting on review and approval of the Ash Basin Closure Plan (Amended, Revision 1)
by NCDECL additional actions are in process including contracting and detailed planning for the closure work,
development of the new lined landfills in conjunction with excavation of the CCR, final grading of the site and landfills,
and development of stormwater features and vegetative covers.
The enclosed Ash Basin Closure Plan (Amended, Revision 1), also includes a description of the Post -Closure Plan, which
provides a description of the inspection, monitoring, and maintenance activities required to be performed throughout
the 30-year post -closure care period for the closed Basins at the Allen Station.
Respect Illy s mitted,
Paul Draovitch
Senior Vice President
w/attachment: Ash Basin Closure Plan (Amended, Revision 1)
NCDEQ cc: damsafetwe!ncdenr.gov, dea.coalash(Dncdenr_pov, Ed Mussler, Steven Lanter, Toby Vinson, Larry Frost
Duke Energy cc: Jessica Bednarcik, Dan Mc Rainey, Jim Wells, Ed Sullivan, Michael Kafka, Randy Hart, DianaKooser,
CCPRecords��duke-energy.com, Steve Pulley, Charl;e Hiner
AECOM cc: Jay Mokotoff, P.E.